The Role of the Recycler (EoL) in the Battery Passport: what role recycling and processing facilities play in the DPP ecosystem, and what conditions must be met for the passport to genuinely support the circular economy and the recovery of critical raw materials.

The integration of recyclers and end‑of‑life (EoL) processing facilities into the Battery Passport framework is essential for enabling a genuinely circular battery value chain. As the Digital Product Passport (DPP) becomes a central instrument for transparency and regulatory compliance under emerging EU battery legislation, recyclers occupy a pivotal position: they close the material loop by recovering critical raw materials and providing verified data on material yields, environmental performance, and traceability. Their contributions ensure that the passport reflects the real lifecycle of a battery, not merely its production and use phases. For the Battery Passport to effectively support circularity, several conditions must be met. First, data flows from recyclers must be standardized, interoperable, and securely integrated into the DPP infrastructure, enabling accurate reporting of recovery rates and secondary material quality. Second, economic and regulatory incentives must align to ensure recyclers can invest in advanced technologies and digital reporting systems. Third, the passport must recognize and differentiate high‑quality recycling processes, rewarding operators that achieve superior recovery of lithium, nickel, cobalt, and other strategic materials. Finally, governance mechanisms must guarantee data integrity, prevent greenwashing, and ensure that all actors—manufacturers, recyclers, and auditors—operate under harmonized verification rules. When these conditions are met, the Battery Passport becomes more than a compliance tool: it becomes a catalyst for industrial symbiosis, higher‑value secondary materials, and reduced dependence on primary raw material extraction, ultimately strengthening the resilience and sustainability of the battery ecosystem.